FedRAMP Authorization vs. Equivalency: Key Insights for CMMC Compliance

Understanding the distinctions between FedRAMP Authorization and Equivalency is crucial for organizations handling Controlled Unclassified Information (CUI) within cloud services. This knowledge impacts compliance timelines, costs, and the level of effort required during Cybersecurity Maturity Model Certification (CMMC) assessments.

What is FedRAMP?

The Federal Risk and Authorization Management Program (FedRAMP) is a framework designed to ensure that cloud service providers (CSPs) meet stringent security standards when working with federal agencies. Its primary goal is to ensure that cloud services are secure enough to handle federal data, including CUI.

FedRAMP Authorization: The Permanent Solution

Key Characteristics:

• Sponsorship: Requires sponsorship from a federal agency, such as the Department of Defense (DoD).

• Permanence: Once authorized, the CSP's product or service is listed in the FedRAMP marketplace and can be reused across federal agencies.

Process:

• Engage a Third-Party Assessment Organization (3PAO) to conduct a thorough review of the CSP’s security posture.

• Approval is granted by the sponsoring agency after this comprehensive assessment.

Advantages:

• Reusability: Once authorized, other federal agencies can utilize the CSP's services without needing to reassess, streamlining the procurement process.

Impact on CMMC Assessment:

Utilizing FedRAMP Authorized services can simplify the CMMC assessment process for businesses. Assessors can rely on the established security posture of the CSP, potentially reducing the workload and associated costs for the organization.

FedRAMP Equivalency: The Temporary Solution

Key Characteristics:

• Compliance: A CSP must meet the FedRAMP Moderate Baseline without any Plans of Action and Milestones (POAMs) and adhere to DFARS 252.204.7012 for cyber incident reporting.

• Assessment: Equivalency is a point-in-time assessment, and the CSP is not listed in the FedRAMP marketplace.

Process:

• A Certified Third-Party Assessment Organization (C3PAO) conducts a full Security Assessment Plan (SAP) and Security Assessment Report (SAR).

• This process is more time-intensive due to the lack of an existing FedRAMP body of evidence.

Challenges:

• Documentation: Organizations must ensure they have access to all necessary documentation from the CSP.

• Time Commitment: The assessment process requires more time with the C3PAO, which can lead to delays.

Impact on CMMC Assessment:

Using FedRAMP Equivalent services necessitates additional time and documentation during CMMC assessments. Organizations should plan accordingly to avoid potential delays.

Comparing Authorization and Equivalency

Key Differences:

• Authorization: Requires sponsorship and provides a permanent, reusable solution.

• Equivalency: Is a point-in-time assessment without a marketplace listing.

Impacts on Businesses:

• Authorized Services: Streamline the assessment process, reducing effort and potential costs.

• Equivalent Services: Require more effort and planning from the organization seeking certification.

Actionable Advice for Organizations

When to Use Authorized vs. Equivalent Services:

• Starting Fresh: Aim for FedRAMP Authorized services whenever possible to simplify your CMMC assessment and reduce the burden on your team.

• Existing Use of Equivalent Services: Gather all necessary documentation upfront and work closely with your CSP and C3PAO to avoid delays.

Planning Ahead:

• Engage Early: Communicate with your CSP early in the process to understand their status and ensure they meet your compliance needs.

Understanding the differences between FedRAMP Authorization and Equivalency is essential for organizations aiming to maintain compliance and streamline their CMMC assessment processes. By carefully selecting and working with CSPs that align with your compliance strategy, you can reduce effort, save costs, and ensure a smoother path to certification.

If you have questions about what we've covered or need assistance navigating FedRAMP and CMMC compliance, we're here to help. Schedule a free 10-minute discovery call with our experts to fast-track your compliance journey. Contact us today to get started.